Sandoval v. County of Sonoma, No. 16-16122 (9th Cir. 2018)
Annotate this Case
Plaintiffs filed suit under 42 U.S.C. 1983 and state civil rights law, contending that the impoundment of their vehicles by local authorities based on plaintiffs' lack of a driver's license violated the Fourth Amendment. California Vehicle Code 4602.6(a)(1) provides that a peace officer may impound a vehicle for 30 days if the vehicle’s driver has never been issued a driver's license.
Applying Brewster v. Beck, 859 F.3d 1194, 1196–97 (9th Cir. 2017), the panel held that 30-day impounds under section 14602.6 are seizures for Fourth Amendment purposes. Therefore, the only issue in this case was whether the impounds were reasonable under the Fourth Amendment. The panel held that, although the state's interest in keeping unlicensed drivers off the road is governed by the community caretaking exception of the Fourth Amendment, the exception does not categorically permit government officials to impound private property
simply because state law does. Furthermore, even if the panel were to balance the state's interest against the driver's interests, the County would still be wrong to rely on a deterrence or administrative penalty rationale to support California's interests. Therefore, the panel affirmed the district court's grant of summary judgment for plaintiffs on the Fourth Amendment claims.
The panel affirmed the district court's grant of summary judgment on plaintiffs claim that the County and the City were liable for money damages as final policymakers who caused the constitutional violations; affirmed the denial of class certification for lack of commonality and typicality; and affirmed summary judgment for defendants on the California Bane Act claim.
Court Description: Civil Rights. The panel affirmed the district court’s summary judgment and its denial of class certification in an action brought pursuant to 42 U.S.C. § 1983 and state law by two plaintiffs whose vehicles were impounded for 30 days because they had not been issued California driver’s licenses. California Vehicle Code § 14602.6(a)(1) provides that a peace officer may impound a vehicle for 30 days if the vehicle’s driver has never been issued a driver’s license. California authorities interpreted section 14602.6 as applying to individuals who had never been issued a California driver’s license. Applying this interpretation, law enforcement officials impounded plaintiffs’ vehicles for 30- days even though plaintiffs attempted to have friends with valid California licenses take possession of the vehicles. Citing Brewster v. Beck, 859 F.3d 1194, 1196–97 (9th Cir. 2017), the panel first noted that 30-day impounds under section 14602.6 are seizures for Fourth Amendment purposes and that the only issue in this case was whether the impounds were reasonable under the Fourth Amendment. The panel held that although the state’s interest in keeping unlicensed drivers off the road provided a “community caretaking” exception to the Fourth Amendment, the application of the exception turned on the facts and
Some case metadata and case summaries were written with the help of AI, which can produce inaccuracies. You should read the full case before relying on it for legal research purposes.
This site is protected by reCAPTCHA and the Google Privacy Policy and Terms of Service apply.